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E-Invoicing under Rule 48(4) - Applicability, Process & Exemptions

# E-Invoicing under GST [Rule 48(4)]

## What is E-Invoicing?

E-invoicing does NOT mean generating invoices on a Government portal. Taxpayers continue to generate invoices in their own accounting/billing/ERP systems. The invoice details are then reported electronically to the Invoice Registration Portal (IRP) as per the e-invoice schema.

### Process Flow

1. Supplier creates invoice in own ERP/billing software.

2. Invoice details uploaded in Form GST INV-01 on the IRP.

3. IRP generates a unique Invoice Reference Number (IRN) and digitally signs the e-invoice.

4. Signed e-invoice + IRN returned to supplier.

5. Invoice is valid only with a valid IRN.

> Currently covered: invoices, credit notes, debit notes issued by notified persons for B2B transactions and exports.

## Applicability — Who Must Issue E-Invoice?

Mandatory for taxpayers whose aggregate turnover (PAN-based) in ANY preceding FY from 2017-18 onwards exceeds Rs. 5 crore ("notified persons").

ScenarioE-invoice Applicable?
Notified person — B2B supplies and exportsYES
Notified person — B2C suppliesNO
Notified person — supplies under RCM u/s 9(3)YES (invoice issued by notified supplier)
Supplies received by notified person from unregistered persons under RCM u/s 9(4) / import of servicesNO
Import of goodsNO

## Persons EXEMPT from E-Invoicing

Even if turnover exceeds Rs. 5 crore, the following are exempt:

1. Special Economic Zone (SEZ) UNITS (note: SEZ developers are NOT exempt — they must issue e-invoices if turnover > Rs. 5 crore)

2. Insurer / Banking Company / Financial Institution including NBFC

3. GTA (Goods Transport Agency) supplying transportation of goods by road in a goods carriage

4. Supplier of passenger transportation services

5. Supplier of services by way of admission to exhibition of cinematograph films in multiplex screens

6. Government Department / Local Authority

> Supplies TO SEZ units: A notified person supplying to an SEZ unit must still issue an e-invoice — exemption is from the SEZ unit's own outward supplies, not from receiving e-invoices.

> Mandatory Declaration: Exempt taxpayers (above the e-invoice threshold but in an exempt category) must add a declaration on the invoice stating they are not required to issue an e-invoice despite crossing the threshold.

## Statutory Hooks [Rule 48(4)]

  • Notified registered persons must prepare invoice by uploading details in Form GST INV-01 and obtaining an IRN.
  • The Commissioner, on Council's recommendation, may exempt persons/classes for a specified period, with conditions.
  • An invoice issued outside Rule 48(4) by a notified person is NOT a valid invoice.
  • Where e-invoicing applies, no triplicate / duplicate copies are required (digital IRN-backed copy is the valid invoice).

## Advantages of E-Invoicing

1. Auto-population of B2B invoice data into GST returns and auto-generation of e-way bills — reduces duplication across GSTR-1 and e-way bill.

2. Fewer transcription errors — same data flows to tax department and buyer, easing reconciliation with the Purchase Order.

3. Standardisation & interoperability — fewer disputes, faster payment cycles, better efficiency.

4. Complete trail of B2B invoices enables system-level ITC vs output tax matching — reduces evasion.

5. Curbs fake invoices — real-time data access to tax authorities helps eliminate fraudulent ITC claims.

Worked example

### Example 1

Threshold Check — When Did You Cross Rs. 5 Crore?: A company's PAN-based aggregate turnover was Rs. 3 crores in FY 2018-19, Rs. 6 crores in FY 2019-20, and Rs. 4 crores in FY 2020-21.

Answer: Since turnover crossed Rs. 5 crores in any preceding FY from 2017-18 onwards (specifically FY 2019-20), e-invoicing applies from the prescribed date and continues even though later years dropped below Rs. 5 crore.

### Example 2

B2C Supplies by a Notified Person: A notified person makes both B2B and B2C supplies.

Answer: E-invoice mandatory for B2B + exports; NOT for B2C. (B2C tax invoices must, however, carry a dynamic QR code for separate notified taxpayers.)

### Example 3

SEZ Unit vs SEZ Developer: Both SEZ Unit X (turnover Rs. 8 crores) and SEZ Developer Y (turnover Rs. 8 crores) make supplies.

Answer: SEZ Unit X — exempt from e-invoicing. SEZ Developer Y — must issue e-invoices. Both, when receiving supplies from a notified supplier, will receive e-invoices.

### Example 4

RCM under 9(3) vs 9(4): Notified supplier supplies GTA services (where recipient pays RCM under 9(3)) vs. notified person receives services from unregistered person (9(4)).

Answer: For 9(3) outward supplies — notified supplier issues an e-invoice. For 9(4) inward supplies under RCM — no e-invoice (recipient issues self-invoice but it is not under e-invoicing scheme).

⚠️ Common exam mistakes

  • Believing e-invoices are generated on the GST portal — they are generated in the taxpayer's own ERP and only reported to IRP for IRN.
  • Applying the Rs. 5 crore threshold to current year only — it is triggered by ANY preceding FY from 2017-18 onwards.
  • Assuming SEZ developers are exempt — only SEZ UNITS are exempt; developers must issue e-invoices.
  • Issuing e-invoices for B2C supplies — not required (those carry dynamic QR code separately for notified persons, but not the IRN-based e-invoice).
  • Treating import of goods or RCM under 9(4) as requiring e-invoicing — both are outside scope.
  • Forgetting the mandatory declaration on the invoice where the taxpayer is above threshold but exempt by category.
Bare-Act text Rule 48(4), (5) & (6) · CGST Rules, 2017 · click to expand
Rule 48(4): The invoice shall be prepared by such class of registered persons as may be notified by the Government, on the recommendations of the Council, by including such particulars contained in FORM GST INV-01 after obtaining an Invoice Reference Number by uploading information contained therein on the Common Goods and Services Tax Electronic Portal in such manner and subject to such conditions and restrictions as may be specified in the notification. Provided that the Commissioner may, on the recommendations of the Council, by notification, exempt a person or a class of registered persons from issuance of invoice under this sub-rule for a specified period, subject to such conditions and restrictions as may be specified in the said notification. Rule 48(5): Every invoice issued by a person to whom sub-rule (4) applies in any manner other than the manner specified in the said sub-rule shall not be treated as an invoice. Rule 48(6): The provisions of sub-rules (1) and (2) shall not apply to an invoice prepared in the manner specified in sub-rule (4).
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